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    HMRC nudge letters to ‘Persons of Significant Control’

    HMRC are currently in the process of sending out nudge letters to ‘Persons of Significant Control’ (PSC) who have either not completed a tax return, or who have completed a tax return in 2021/22, but whose income is ‘lower compared to most in a similar position’.

    HMRC’s Wealthy External Forum have begun posting ‘One to Many’ letters to PSCs listed at Companies House, with the PSC classified as someone who owns or controls the company. According to HMRC, a PSC is a person who:

    • Owns more than 25 per cent of shares in the company;
    • Owns more than 25 per cent of voting rights in the company;
    • Has the right to appoint or remove the majority of the board of directors;
    • Can exercise significant influence over the company

    HMRC’s ‘One to Many’ approach allows them to target a wide range of taxpayers regarding a specific issue where the data suggests there may be a reason for non-compliance. The letters are urging recipients to check, and where necessary, correct their tax returns.

    Those who have not completed a return will be directed to an online checker to determine whether they should be completing returns. Those whose disclosed income is thought to be incorrect will be invited to amend their 2021/22 tax return, and ensure their 2022/23 return includes the additional income.

    Recipients of HMRC’s ‘One to Many’ letters have until 18 August 2023 to respond.

    If you have received a HMRC letter, we recommend speaking to your adviser to obtain immediate professional advice before responding particularly if you currently hold fee pro cover.

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    Contact a member of the PM+M tax team by emailing to discuss your situation in more detail.

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